Carolyn Dallas-Clark v. John Eilert

CourtDistrict Court, W.D. Kentucky
DecidedOctober 20, 2025
Docket4:23-cv-00036
StatusUnknown

This text of Carolyn Dallas-Clark v. John Eilert (Carolyn Dallas-Clark v. John Eilert) is published on Counsel Stack Legal Research, covering District Court, W.D. Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Carolyn Dallas-Clark v. John Eilert, (W.D. Ky. 2025).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF KENTUCKY OWENSBORO DIVISION

CAROLYN DALLAS-CLARK Plaintiff

v. Case No. 4:23-cv-36-RGJ-HBB

JOHN EILERT Defendant

MEMORANDUM OPINION & ORDER

Plaintiff Carolyn Dallas-Clark (“Dallas-Clark”) moves for an award of attorney’s fees. [DE 102]. Defendant John Eilert (“Eilert”) responded [DE 103] and, Dallas-Clark replied [DE 104]. Dallas-Clark submitted a bill of costs, to which Defendant did not file an objection. [DE 101]. This matter is ripe. For the reasons below, Dallas-Clark’s Motion for Attorney’s Fees [DE 102] is GRANTED and Dallas-Clark’s Bill of Costs [DE 101] is GRANTED. I. BACKGROUND The Court incorporates the procedural and factual background set forth in its order on Defendant’s motion for summary judgment. [DE 44]. This action came before the Court for a jury trial on August 11, 2025 and concluded on August 12, 2025. [DE 85; DE 90]. The jury found for Dallas-Clark on her claim that Eilert used excessive force while arresting her, in violation of her Fourth Amendment rights. [DE 100 at 1878]. The jury awarded Dallas-Clark $15,000 in compensatory damages. [Id.]. Dallas-Clark asked for approximately $3,000,000.00 in damages in her Amended Complaint. [DE 6 at 28]. Dallas-Clark moves for attorney’s fees and costs, arguing that she is entitled to them as a prevailing party. [DE 102 at 1891-92]. In response, Eilert asserts that although Dallas-Clark is a prevailing party, the “requested hourly rate is unsupported by any evidence,” the “requested fee amount is excessive as it relates to the result obtained,” and “enhancement is not appropriate.” [DE 103 at 1907-09]. Additionally, Dallas-Clark filed a separate Bill of Costs. [DE 101]. Eilert did not file an objection to the Bill of Costs, nor did he mention it in response to Dallas-Clark’s motion for attorney’s fees. II. DISCUSSION 1. Dallas-Clark’s Motion for Attorney Fees The general rule is that each party must pay its own attorney’s fees and expenses. Hensley

v. Eckerhart, 461 U.S. 424, 429 (1983). However, Title 42 U.S.C. § 1988(b) provides that in actions to enforce § 1983, “the court, in its discretion, may allow the prevailing party . . . a reasonable attorney’s fee . . .” The “threshold determination” for district courts is whether the party seeking fees prevailed. Hensley, 461 U.S. at 433. If a party prevailed, any fee awarded must be reasonable, meaning that it “is adequately compensatory to attract competent counsel yet which avoids producing a windfall for lawyers.” Adcock-Ladd v. Sec’y of Treasury, 227 F.3d 343, 349 (6th Cir. 2000); see also Perdue v. Kenny A. ex rel. Winn, 559 U.S. 542, 552 (2010) (cleaned up) (explaining that the goal of the fee-shifting statutes is “to induce a capable attorney to undertake the representation of a meritorious civil rights case” . . . “not to provide a form of economic relief to improve the financial lot of attorneys”).

A district judge’s exercise of discretion in statutory fee award cases is entitled to substantial deference, especially when the rationale for the award was predominantly fact-driven. Id. (citing Hensley, 461 U.S. at 437); Wilson–Simmons v. Lake County Sheriff’s Dept., 207 F.3d 818, 823 (6th Cir. 2000); Hadix v. Johnson, 65 F.3d 532, 534–35 (6th Cir. 1995). In exercising its discretion, the district court “must provide a clear and concise explanation of its reasons for the fee award.” Hadix, 65 F.3d at 535 (citing, inter alia, Hensley, 461 U.S. at 437). Relevant here, is that the Sixth Circuit has noted that attorney’s fees may be warranted when a trial court aptly explains that “fees [are] warranted to vindicate [] important constitutional right[s] for arrestees to be free from the excessive use of force.” Ward v. Borders, et al, 2024 WL 4242059 (W.D. Ky. Sep. 19, 2025), aff’d No. 24-5920 slip op. at 4 (6th Cir. Oct. 14, 2025). Here, Dallas-Clark moves for attorney fees as the prevailing party on the § 1983 excessive force claim against Eilert. Dallas-Clark argues that because “the fee was contingent in this matter as [Dallas-Clark] was in no position to pay,” and that the “case involved significant risk to the law

firm of [Dallas-Clark’s] counsel as a contingency case involving a claim of civil rights violation by a law enforcement officer” counsel is entitled to fees. [DE 102 at 1893]. Eilert contends that the requested rate, $350.00 per hour, has no evidentiary support, is excessive compared to the result obtained, and the requested enhancement is not appropriate. [DE 103 at 1907-09]. a. Prevailing Party Status Title 42 U.S.C. § 1988(b) provides that in actions to enforce § 1983, “the court, in its discretion, may allow the prevailing party . . . a reasonable attorney’s fee.” Farrar v. Hobby, 506 U.S. 103, 109 (1992). “A judgment for damages in any amount, whether compensatory or nominal, modifies the defendant's behavior for the plaintiff’s benefit by forcing the defendant to pay an

amount of money he otherwise would not pay.” Id. at 113. Even so, the Supreme Court has noted that while “a plaintiff who wins nominal damages is a prevailing party under § 1988,” the “technical” nature of an award of damages bears on the reasonableness of fees awarded under § 1988. Id. In some circumstances, “even a plaintiff who formally ‘prevails’ under § 1988 should receive no attorney’s fees at all.” Id. at 114. Although the plaintiffs had been the prevailing party in the litigation, the district court in Farrar had abused its discretion by awarding “attorney’s fees without ‘consider[ing] the relationship between the extent of success and the amount of the fee award.’” Id. at 115–16 (quoting Hensley, 461 U.S. at 438). As the Supreme Court has explained, civil-rights plaintiffs “seek [] to vindicate important civil and constitutional rights that cannot be valued solely in monetary terms.” City of Riverside v. Rivera, 477 U.S. 561, 574–80 (1986). As a result, “Congress enacted § 1988 specifically to enable plaintiffs to enforce the civil rights laws even where the amount of damages at stake would not otherwise make it feasible to do so.” Id. at 577. Moreover, the Sixth Circuit has observed that a

rule eliminating attorneys’ fees in civil-rights cases “due to the size of the damages awarded ‘would seriously undermine Congress’ purpose in enacting § 1988,’” and the court expressly “refuse[d] to countenance a decision that does so.” Hescott v. City of Saginaw, 757 F.3d 518, 525 (6th Cir. 2014) (quoting City of Riverside, 477 U.S. at 576). Placing too great an emphasis on the amount of damages awarded would “detrimentally encourage attorneys to concentrate on increasing the damage award, perhaps with harm to the merits of the case; moreover, transfixion on the damage amount in establishing fees would penalize those litigants whose cases carry slight pecuniary damages, but which present instances of significant statutory violations.” United Slate, Tile & Composition Roofers, Damp & Waterproof Workers Ass’n, Local 307 v. G & M Roofing &

Sheet Metal Co.

Related

Hensley v. Eckerhart
461 U.S. 424 (Supreme Court, 1983)
City of Riverside v. Rivera
477 U.S. 561 (Supreme Court, 1986)
City of Burlington v. Dague
505 U.S. 557 (Supreme Court, 1992)
Farrar v. Hobby
506 U.S. 103 (Supreme Court, 1992)
Pollard v. E. I. Du Pont De Nemours & Co.
532 U.S. 843 (Supreme Court, 2001)
Fox v. Vice
131 S. Ct. 2205 (Supreme Court, 2011)
Loranger v. Stierheim
10 F.3d 776 (Eleventh Circuit, 1994)
Everett Hadix v. Perry Johnson
65 F.3d 532 (Sixth Circuit, 1995)
Theresa Waldo v. Consumers Energy Company
726 F.3d 802 (Sixth Circuit, 2013)
Garner v. Cuyahoga County Juvenile Court
554 F.3d 624 (Sixth Circuit, 2009)
Imwalle v. Reliance Medical Products, Inc.
515 F.3d 531 (Sixth Circuit, 2008)

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Bluebook (online)
Carolyn Dallas-Clark v. John Eilert, Counsel Stack Legal Research, https://law.counselstack.com/opinion/carolyn-dallas-clark-v-john-eilert-kywd-2025.